Acheiving Compliance Through People
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Transcript of Acheiving Compliance Through People
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ACHIEVING COMPLIANCE THROUGH PEOPLE: TRAINING SUPERVISORS TO TACKLE
PROCEDURAL NON-COMPLIANCE
Paul Leach
1
, Jonathan Berman
1
and David Goodall
2
1Greenstreet Berman Ltd, London, UK 2National Grid, UK
All organisations face the challenge of improving compliance. For many, the challenge is increased
by the nature of the workforce, which may be both constantly changing, and working away from a
fixed location. In such circumstances, there is significant reliance on local supervision to control the
work, and instil the necessary culture and attitudes. For such organisations, it is apparent that the
local supervisor is a key element in any compliance enhancement process.
Over the last two years Greenstreet Berman has been developing a programme to help a national
utility organisation tackle procedural team non-compliance through the effective development of
supervisors. The programme has led to the creation of a Supervisor Development Centre. This
centre focuses on providing supervisors with the leadership and supervisory skills to ensure they
can effectively identify, challenge and rectify team procedural non-compliance while on site and
thus improve the overall safety of operations.The development centre looks at procedural non-compliance relating both to occupational health
and safety and to process safety. A key element of the approach is to use picture-based and live
mock-up scenarios to help supervisors practice their skills and allow an assessment of competence
to take place, which can feed into on-going competence management arrangements.
The overall approach recognises that each supervisor comes not only with different levels of
‘compliance management competence’, but also with different interpersonal skills and approaches.
Consequently the development centre is oriented around enabling participants to understand and
recognise their own strengths and limitations, as well as recognising positive and negative beha-
viours in the staff they are supervising.
This paper discusses the development and implementation of the supervisor development centre.
The paper will briefly summarise the background to the development of the centre, detail the meth-
odology used to identify relevant competencies and training requirements, describe the centre aims
and content and finally provide some indication of the value of the centre, based on anecdotalparticipant feedback. It will draw out the implications for any organisation that wishes to
enhance compliance.
KEYWORDS: Training, Competence Management, Leadership, Supervision
INTRODUCTION
Procedural compliance is an essential element of safety
management, in terms of occupational health and safety
and process safety and business management, in terms of
improving performance, enhancing reputation and reducing
costs (i.e. costs associated with re-work, damage to
materials and other assets, and those that can arise from
incidents and accidents).However the effective management of procedural
compliance is a significant challenge and organisations
need solutions that provide long-term sustainable improve-
ment. To do this, there needs to be a move away from focus-
ing solely on surface issue solutions such as procedural and
task re-design and start to consider how an organisation can
foster and install positive safety behaviours in their teams.
Indeed for this to occur the local supervisor becomes a
key element in the enhancement of compliance, as for
many organisations, site teams change regularly and work
away from a fixed location.
Research indicates that the supervisor plays a crucial
role in the management of team safety, a key element of
which is procedural compliance.1 Effective supervision
has been shown to have a positive and long lasting effect
on team performance, compliance, injury rate, delays and
costs.2,3 This is essentially because supervisors have the
greatest opportunity to influence team behaviour, and
through their own behaviour, foster and instil the necessary
culture and attitudes within their teams.
It is therefore in recognition of the crucial role super-visors play, that Greenstreet Berman Ltd in collaboration
with National Grid have developed the Supervisor Develop-
ment Centre, to help supervisors develop the skills they
require to successfully tackle procedural non-compliance
through fostering and installing positive safety behaviours
in their teams.
1HSE (1999) Effective Supervisory Safety Leadership Behaviors in the
Offshore Oil and Gas Industry.2Greenstreet Berman (2008) Managing Driver Managers.3Rail Safety and Standards Board (2009) Understanding Human
Factors.
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RATIONAL FOR THE SUPERVISOR
DEVELOPMENT CENTRE
Over the past few years National Grid has been implement-
ing a compliance management improvement program across
the organisation to improve the level of compliance withengineering standards and safe working practices. Their
key objectives are to:
. Ensure public safety – this includes immediate public
safety when carrying out work in areas where
members of the public could be affected e.g. signage,
lighting and guarding issues;
. Improve process safety – this refers to the quality and
integrity of work carried out e.g. pipework is replaced
according to procedures to ensure that it has the
desired integrity and is not at risk of failure sooner
than expected;
. Ensure employee health and safety – risk of injury/
death (e.g. slips, trips, falls etc.).
National Grid recognised that supervisors are
pivotal in improving standards and compliance as they
have direct influence on teams and consequently required a
solution to be focused at this level to ensure that supervisors
have the necessary skills to effectively lead and manage their
teams to ensure team compliance with National Grid engin-
eering standards and safe working practices. Moreover,
National Grid required a solution that provide sustainable
long-lasting results and that would have a observed positive
benefits on performance, reputation and cost.
Greenstreet Berman was commissioned by National
Grid to provide overall support on the compliance
program and to specifically develop the Supervisor Devel-opment Centre. This is because Greenstreet Berman has
considerable experience of supporting compliance improve-
ment programs and developing safety leadership and behav-
ioural safety training, that provide sustainable safety and
business improvements.
DEVELOPMENT OF THE CENTRE
The centre was developed from three approaches – job
analysis workshops, training review and stakeholder discus-
sions – along with Greenstreet Berman’s general expertise
in safety leadership issues. This triangulation of approaches
was applied to ensure the course was built around the
specific requirements of National Grid and key competen-cies required for supervisors to effectively tackle team
non-compliance.
JOB ANALYSIS WORKSHOPS
Two job analysis workshops were carried out with National
Grid supervisors. Each workshop had approximately 8–10
supervisors and lasted a full day. Supervisors were selected
from across the organisation to ensure diversity within the
sample.
The objectives of the workshops were to:
. Understand the context and current roles of the supervi-
sors;
. Identify supervisor perceptions of their current role and
key priorities;
. Identify key tasks and behaviours associated with good
and poor performance;
. Identify training already provided – particularlyelements identified as being particularly good or poor;
. Identify real and perceived barriers to compliance –
both for teams and supervisors.
TRAINING REVIEW
A training review was carried out to understand the type
of training provided to supervisors and the general structure
of the training packages currently being delivered. The
review was carried out through discussions with the training
department around the types of training provided and a
review of several different training packages.
STAKEHOLDER DISCUSSIONSA number of stakeholder discussions were held with key
members of the compliance improvement strategy team.
The discussions were used to help identify what National
Grid required from the course, that is, what was the per-
ceived success criteria and what type of information was
required from the course in terms of assessment of compe-
tence. The discussions were also used to help National Grid
think about and identify the types of competencies and
behaviours they expected from supervisors that could then
be integrated into the course.
FINDINGS
The job analysis workshops, training review and stake-holder discussions highlighted a number of key findings:
. The role of the supervisor was revealed as being
complex with many differing, and potentially competing
priorities. There was an apparent lack of clarity on
National Grid’s expectation on the key priorities and
activities;
. Supervisors recognised safety as a key part of their
responsibilities but had received little if any training
on safety leadership;
. Three key supervisor competencies were identified for
the successful management and enhancement of team
non-compliance:
W
Observation – accurate identification and under-standing of non-compliance on site;
W Challenging – confidence and motivation to chal-
lenge all non-compliances identified on site, remain-
ing in control of interactions with teams, setting
clear expectations of behaviour and ensuring
that corrective action is taken to rectify the non-
compliance;
W Coaching – effective questioning and listening
to help teams understand and identify for them-
selves non-compliances, consequences of the non-
compliance and required corrective actions.
. Current training combined both presentation and pra-
ctical elements. Training packages that were highly
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interactive and practical were considered to be the most
successful programs. However the majority of training
provided related to technical and process knowledge
and practice and not safety leadership and safety
management;. National Grid required a program that firstly helped
develop the competence of supervisors but also provided
an assessment of performance and competence to aid
further development activity once the supervisor had
finished the course.
These findings were used to develop and structure the
course aims and content.
AIMS OF THE DEVELOPMENT CENTRE
Thekey aimof thedevelopment centre is to allow supervisors
to learn, practice and develop the key competencies needed
to effectively tackle and enhance team non-compliance, in
a supportive environment where they can receive feedback
on their performance from their peers and the facilitators.
Indeed it is for this reason that the training package
has been titled a “development centre” as opposed to a train-
ing course. This is because a “development centre” is a
specific type of training event that uses a package of
inputs, exercises and scenarios that simultaneously assess
an individual’s performance and provide development
opportunities to meet a required level of competence.
The specific aims of the centre are to:
. Help supervisors clearly understand their role and
responsibilities as supervisors;
. Enhance the supervisor’s ability to influence team beha-
viours to stop non-compliance and thus perform through
their teams (through observation, challenging and
coaching);
. Allow supervisors to practice these competencies and
learn from their peers in a supportive environment;
. Identify on-going development needs.
STRUCTURE OF THE DEVELOPMENT CENTRE
The development centre is structured into several
components – pre-course work, during the centre and post
course continuous learning.
PRE-COURSE WORK
Research indicates that manager feedback and the use of
self-reflective questionnaires can help learners identify
current strengths and weakness in their style of working
and supervision.4
Therefore before taking part in the development
centre each supervisor is required to complete pre-course
work. This consists of completing a leadership impact ques-
tionnaire, which takes around 30 minutes. An individual lea-
dership impact report is generated for each supervisor and
used within the centre to help supervisors think about
their leadership style and its impact on team performance.
The supervisor’s line manager is also requested to
provide feedback on the supervisor’s performance to help
the supervisor during the development centre think aboutareas of strength and weakness and identify relevant devel-
opment steps to improve performance.
DURING THE CENTRE
The centre lasts 2 12
days and is structured around the learn-
ing cycle, combining both input sessions and practice ses-
sions, with feedback to enhance the learning experience of
delegates. This has been shown to be a very effective
method for learning and development.5
Input sessions – throughout the 2 12
days a range of
input sessions are provided, using Powerpoint and group
based activities. These sessions last around 20 minutes to
an hour depending on topic and cover areas such as:. Roles and responsibilities of supervisors;
. Coaching for compliance;
. Leadership and safety leadership (structured around the
leadership impact report and manager feedback);
. Risk based decision making (using picture based exer-
cises of non-compliance);
. Challenge, interacting and providing feedback (using
video clips, pictures of non-compliance, group exer-
cises);
. Risk assessment (key component involves a risk assess-
ment using the PTW for deep excavation);
. Setting standards and influencing people – (particularly
focus on why people do not comply, supervisor beha-viours that can influence non-compliance and the key
opportunities supervisors have to influence their teams);
. Time management;
. HSE responsibilities – based around a video interview
of a supervisor who was involved in an HSE investi-
gation.
Picture based scenarios – the picture based scenarios
are a key component of the development centre and allow
the supervisor to practice the required competencies
within a realistic setting.
For each picture based scenario session (initial site
inspection, return site inspection, team brief and individual
coaching) supervisors are split into two groups of four, withone facilitator per group. Within each group an individual
will be selected to play the role of the supervisor for the
scenario, two other group members will be selected to
play the team and one group member will be required to
play the observer. The individual playing the supervisor is
given some pictures of non-compliance that represents the
team’s job. The supervisor and team are required to act as
though they are on-site. The supervisor is required to
rectify the situation and the individuals playing the team
are provided with role play instructions and encouraged
to be challenging. The scenario usually runs for about4Doyle (2003) Work and Organizational Psychology. An Introduction
with Attitude. 5Buckley and Caple (2004) The Theory and Practice of Training.
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5–10 minutes until the situation is resolved or reaches a
natural conclusion.
During the scenario the facilitator observes the super-
visor’s behaviour and uses a set of detailed observation cri-
teria to help make notes on key behaviours exhibited by thesupervisor during the scenario.
Once the scenario has finished each group member
provides feedback on the supervisor’s performance, high-
lighting strengths and development areas. The facilitator
then provides feedback based on their observations.
The whole process is then repeated using different
pictures until all members of the group have played the
role of the supervisor.
Each picture based scenario session increases with
difficulty as the centre continues, i.e. for each session super-
visors are expected to apply more sophisticated behaviours
to help tackle the problem. This therefore allows supervisors
to apply skills and increase competence as the centre
progresses.
Live mock-ups – the development centre is run at the
National Grid Skills Development Centre in Hitchin which
has the facility to run live mock-ups of deep excavations,
service connections and street walkthroughs. Live mock-
ups are therefore used within the centre to provide a
further opportunity for supervisors to practice skills and
receive feedback on performance.
Six live mock-up sessions are carried out within the
centre:
. Two deep excavation sessions with non-compliances
relating to trench support, PPE and PTW;
. Two service connections with non compliances relating
to pipe integrity;
. Two initial site briefing walkthroughs.
The live mock up sessions are structured exactly the
same as the picture based scenario sessions but use real-
live mock-ups to make the situation as real as possible.
This has proven to be very useful in providing a more
testing challenge, particularly on observation skills, than
the picture based scenarios. Additionally, the supervisors
like the more realistic site situation.
POST COURSE CONTINUOUS LEARNING
Research indicates that learning and development inter-
ventions often fail to produce long term benefits becauseorganisations do not implement effective processes and
systems to support continuous learning and development.6,7
Therefore after the development centre a develop-
ment needs report is developed for each supervisor who
has attended the centre. This report collates the facilitator’s
observations of the supervisor’s performance and behaviour
during the course, particularly within the scenarios.
The report is broken down into five sections:
– Demonstration of the key competencies – for each of the
key competencies (observation, challenging and coach-
ing) a performance rating is given (well above
minimum, satisfactory or needs improvement), along
with information on strengths, development areas and
recommended actions to help enhance performance on
that key competence.
– Leadership style – the leadership impact report is sum-
marised to help the line manager and supervisor clearly
understand the supervisor’s leadership style and the
impact, both positive and negative, the style can have
on team performance.
– Attitude on course – a summary is provided of the
supervisor’s attitude on the course, whether they
engaged with the material, were keen to learn, etc,
thus providing an indication of their aptitude for learn-
ing and willingness or resistance to change.– Overall comment – an overall comment is provided for
the supervisor based on all observations during the
course. This essentially summarises the previous sec-
tions, particularly their observed level of competence
demonstrated on the course and their attitude.
– Mentoring activities – a list of relevant mentoring
activities is provided based on the observations of per-
formance, identified development needs and rec-
ommended actions to improve performance. The aim
of this section is to provide the supervisor’s manager
with ideas and guidance on how they can help the super-
visor continue to develop and improve once they are
back in the workplace.
The key aim of the report is to facilitate and help the
manager and supervisor identify and implement mentoring
and development activities to ensure the supervisor can con-
tinue to learn, develop and improve. Moreover, information
within the report is only based on observations during the
centre and hence the managers are encouraged to use the
reports in conjunction with other relevant performance
data to help identify development and mentoring activities.
REPORTED BENEFITS
The supervisor development centre has been running
since September 2008 (progressively improving as timepasses) and is now a key component of the National Grid
compliance improvement program, providing a unique
and powerful way of helping to improve procedural com-
pliance. The development centre does this by providing
supervisors with the opportunity to acquire, practice and
apply the skills and behaviours needed to positively influ-
ence teams understanding of, and behaviour to, procedural
compliance.
Feedback from participants of the centre has been
overwhelmingly very positive. Participants have felt that
the centre provides the key skills needed to help tackle
team non-compliance and allows supervisors to not only
practice these skills in realistic situations but also learn
6Doyle (2003) Work and Organizational Psychology. An Introduction
with Attitude.7Buckley and Caple (2004) The Theory and Practice of Training.
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from their peers and learn how other supervisors tackle situ-
ations, thus helping to give supervisors greater confidence
in interacting and dealing with teams who are not complying
with National Grid engineering standards and safe working
practices.Indeed Greenstreet Berman Ltd recently assisted a
National Grid Alliance in identifying and evaluating the
impact of the Supervisor Development Centre. The review
has currently identified the following key business impacts:
. Supervisors have increased confidence in their role;
. Supervisors are stopping unsafe jobs more often because
they are not only more confident of when they should
stop a job but more confident that they will be supported
in doing so;
. Improved compliance across Occupational Health and
Safety and Process Safety measures and belief that the
course will help to sustain this improvement;
. Application of a standardised approach to supervision of teams across the alliance.
The above business impacts are all enablers to
improved safety performance and reductions in accidents
and incidents, thus highlighting the potential impact the
supervisor development centre can have on bottom line
business and safety results.
APPLICATION OF APPROACH
The Supervisor Development Centre can be applied to any
high hazard operational environment where operations are
carried out by teams and require supervision. Moreover,
this work demonstrates supervisors play a critical role in
facilitating long-lasting improvements in compliance and
other relevant business areas and therefore any organisation
looking to improve procedural compliance would benefit
from interventions that aim to help supervisors practice
and develop the necessary skills to foster and install positiveteam behaviors.
Indeed the approach and structure of the development
centre highlights several key learning points, that should be
considered by organisations wishing to develop these type
of interventions:
1. Structuring the intervention around the key skills and
knowledge expected of supervisors to foster positive
safety behaviors, identified through job analysis work-
shops, is essential for ensuring the intervention has
maximum affect;
2. Pre-course feedback and assessments are very effective
methods for helping supervisors consider strengths and
weakness of their supervision style;3. Interventions should be built around the learning cycle,
providing opportunities for theory, practice and feed-
back, helping to cement learning into practice;
4. Use of picture based scenarios and where possible
live mock-ups, allow the supervisor to practice the
required competencies within a realistic setting and
provide a very effective approach to learning and
development, through practice, feedback and peer
learning;
5. Systems for continuous learning should be in place
to ensure development and improvement continues.
Providing development reports after a training interven-
tion can help facilitate this process and provide the
foundations for continued development.
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